Corporate Crime and Senior Manager Liability – 2026 Changes

The Crime and Policing Act 2025 received Royal Assent in April 2026. With this, the legal landscape has shifted dramatically, and there is now a direct personal and organisational risk for senior managers.

Companies and businesses can now be held criminally liable for any offence committed by a senior manager acting within their actual or apparent authority. This change significantly increases the risk of inadequate corporate governance and risk management.

The New Position

Previously, UK corporate criminal liability was generally limited to offences where the “directing mind” of the company concerned could be proven to have committed the crime. However, this was often a high threshold to reach, but the new law widens corporate accountability dramatically.

• A senior manager is anyone who plays a significant role in decision-making or managing a substantial part of the business concerned.
• Any criminal offence, not just financial crimes, if committed in the course of the senior manager’s role is caught by the new law.
• The organisation concerned can be prosecuted even if the directors were unaware of the misconduct.

Risks for Senior Managers

• Personal liability – although the law targets corporate liability, senior managers may still face individual prosecution under existing laws.
• Reputational damage – criminal proceedings against the company can negatively impact reputation and customer trust.
• Regulatory concerns – certain sectors such as financial services, healthcare, and construction face enhanced oversight.

Risk Management for Senior Leaders

Senior managers and leaders should consider the following practical steps to minimise risk:

• Document decision-making processes to ensure transparency.
• Conduct regular legal and ethical training for managers at all levels.
• Implement reporting or whistleblowing systems to allow early detection of misconduct.
• Conduct risk audits to identify and address vulnerabilities.
• Seeking early legal advice can prevent inadvertent breaches.

Conclusion

The latest 2026 reforms mark a significant change in corporate criminal law. Senior managers’ actions can now create potential corporate liability, making proactive compliance both a legal and strategic necessity. Senior managers taking steps to enhance internal processes and leading by example will not only protect themselves and their organisations but also strengthen stakeholder trust in the business concerned.

How Can We Help?

The Corporate and Commercial team at Wilson Browne Solicitors is ideally placed to advise on all aspects of corporate governance and risk management to ensure full compliance with the 2026 reforms. For a confidential and no obligation initial discussion about how we may be able to help, please contact the Corporate and Commercial team at 0800 088 6004.